Micron Tech., Inc. v. Rambus Inc.
United States Court of Appeals for the Federal Circuit
May 13, 2011, Decided
[***1695] [*1315] Linn, Circuit Judge.
Rambus Inc. ("Rambus") appeals the decision of the United States District Court for the District of Delaware holding that the twelve Rambus patents asserted against Micron Technology, Inc., Micron Electronics, Inc., and Micron Semiconductor Products, Inc. (collectively, "Micron") are unenforceable due to Rambus's spoliation of documents. Micron Tech., Inc. v. Rambus Inc., 255 F.R.D. 135 (D.Del. 2009) ("Decision"). Rambus also appeals the district court's order piercing Rambus's attorney-client privilege on the basis of the crime-fraud exception, Micron Tech, Inc. v. Rambus Inc., No. 00-792 (D. Del. Feb. 10, 2006) ("Privilege"), and denial of Rambus's motion to transfer to the Northern District of California, Micron Tech, Inc. v. Rambus Inc., No. 00-792 (D. Del. June 14, 2007) ("Transfer"). For the reasons discussed below, this court affirms-in-part, vacates-in-part, and remands.
This case and the companion case of Hynix Semiconductor Inc. v. Rambus Inc., Nos. 2009-1299, -1347, 645 F.3d 1336, 2011 U.S. App. LEXIS 9728 (Fed. Cir. May 13, 2011) ("Hynix II") (decided contemporaneously herewith), concern a group of U.S. patents issued to Rambus covering various aspects of dynamic [**3] random access memory ("DRAM"). Although semiconductor memory chips have been used in computers for decades, advances in other aspects of computer technology by the early 1990s created a bottleneck in the ability of computers to process growing amounts of data through the memory. At least two related methods were discovered of building memory chips (and the interfaces between memory chips and computer processors) in a way that eliminated or minimized this bottleneck. The founders of Rambus, Mike Farmwald and Mark Horowitz, developed one of these methods, which Rambus later commercialized as Rambus DRAM, or RDRAM. The original Rambus applications claim the inventions [***1696] included in RDRAM. Rambus believed that Farmwald's and Horowitz's invention was broad enough to encompass synchronous dynamic random access memory, or SDRAM, the other type of new memory technology.
Farmwald and Horowitz did not initially file patent applications with claims explicitly directed at SDRAM. However, after Rambus's tenure and resignation as a member of the standard setting Joint Electron Devices Engineering Council ("JEDEC"), Rambus amended its claims to cover the SDRAM technology adopted as the standard by JEDEC. [**4] See generally Rambus Inc. v. Infineon Techs. AG, 318 F.3d 1081 (Fed. Cir. 2003) ("Infineon") (discussing Rambus's participation in JEDEC). The patents at issue here and their enforceability against SDRAM products have been the subject of numerous suits in district courts, the Federal Trade Commission, the International Trade Commission, and this court. However, this court has never finally and definitively resolved the question of whether Rambus engaged in spoliation in connection with this litigation.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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645 F.3d 1311 *; 2011 U.S. App. LEXIS 9730 **; 98 U.S.P.Q.2D (BNA) 1693 ***; 2011 WL 1815975
MICRON TECHNOLOGY, INC., Plaintiff/Counterclaim Defendant-Appellee, AND MICRON ELECTRONICS, INC. AND MICRON SEMICONDUCTOR PRODUCTS, INC., Counterclaim Defendants-Appellees, v. RAMBUS INC., Defendant/Counterclaimant-Appellant.
Subsequent History: As corrected May 16, 2011.
Rehearing denied by, Rehearing, en banc, denied by Micron Tech., Inc. v. Rambus Inc., 2011 U.S. App. LEXIS 16674 (Fed. Cir., July 29, 2011)
On remand at, Findings of fact/conclusions of law at, Judgment entered by Micron Tech., Inc. v. Rambus Inc., 917 F. Supp. 2d 300, 2013 U.S. Dist. LEXIS 154 (D. Del., Jan. 2, 2013)
Prior History: [**1] Appeal from the United States District Court for the District of Delaware in case no. 00-CV-792, Judge Sue L. Robinson.
Micron Tech., Inc. v. Rambus Inc., 255 F.R.D. 135, 2009 U.S. Dist. LEXIS 1260 (D. Del., 2009)
Disposition: AFFIRMED-IN-PART, VACATED-IN-PART, AND REMANDED.
district court, documents, spoliation, patent, bad faith, manufacturers, destroyed, destruction, reasonably foreseeable, licensing, retention, shredding, sanctions, infringement, planned, products, backup, memory, email, tapes, argues, intentionally, technology, chips, litigate, weighing, cases, attorney-client, unenforceable, abused
Evidence, Relevance, Preservation of Relevant Evidence, Spoliation, Civil Procedure, Appeals, Standards of Review, Clearly Erroneous Review, Patent Law, Infringement Actions, General Overview, Abuse of Discretion, Sanctions, Misconduct & Unethical Behavior, Inferences & Presumptions, Inferences, Pleading & Practice, Burdens of Proof, Allocation, Clear & Convincing Proof, Privileges, Attorney-Client Privilege, Exceptions, Criminal Law & Procedure, Criminal Offenses, Miscellaneous Offenses, Venue, Motions to Transfer